Updates to IEC 62474 Declarable Substance List and Data Exchange – September 24, 2014

An update to the IEC 62474 Declarable Substance List (DSL) and data exchange format was released on September 24, 2014. Voting on proposed changes closed on September 12, 2014 — all changes were approved. The DSL has been up-revisioned to version D7.00 and the updated XML schema and associated developer’s table are now version X5.00.

The DSL is an internationally recognized and harmonized list of substances and substance groups that are regulated and may be a constituent of electrotechnical products. Major electrical and electronic manufacturers and suppliers use the DSL in their design and supply chain management operations to specify and control substances of concerns. The list is typically updated twice a year.

Additions to the Declarable Substance List (DSL)

The most recent additions to the DSL are:

  • Disodium 4-amino-3-[[4′-[(2,4-diaminophenyl)azo][1,1′-biphenyl]-4-yl]azo]
    -5-hydroxy-6-(phenylazo)naphthalene-2,7-disulphonate (C.I. Direct Black 38) (EU REACH SVHC)
  • Diisohexyl phthalate (DiHP) (EU REACH SVHC)
  • Diisononyl phthalate (DINP) (California Prop 65)
  • The eight polycyclic aromatic hydrocarbon (PAH) (EU REACH ANNEX XVII)

Direct Black 38 is a REACH SVHC that was added to the Candidate list in December 2013; however, it’s addition to the IEC 62474 DSL required further assessment and therefore was not added during the previous update in April 2014.

Of the four SVHCs added to the REACH Candidate List in June 2014, DiHP is the only SVHC that passed the IEC 62474 screening process as a possible constituent in EEE products above the reporting threshold. The other three SVHCs are intermediate substances which did not pass the screening process.

For the polycyclic aromatic hydrocarbon (PAH) substances, it’s important to note that each PAH substance appears in two separate entries with two different reportable applications and reporting thresholds.

Modifications to existing entries

  • Brominated flame retardants (other than PBBs, PBDEs, or HBCDD) – the reporting threshold was updated to more clearly indicate that the mass percent needs to be calculated at the material level (0.1 mass% of bromine in plastic materials)
  • Chlorinated Flame Retardants (CFR) – the reporting threshold was updated to more clearly indicate that the mass percent needs to be calculated at the material level “0.1 mass% chlorine in plastic materials”
  • Shortchain Chlorinated Paraffins (C10 – C13) – the reporting threshold was updated to “Intentionally added or 0.1 mass%” based on the EU POP regulation
  • Perfluorooctane sulfonates (PFOS) – the existing entry is being replaced by two separate entries to reflect the different reporting thresholds for “Textiles or other coated materials” versus other applications
  • Hexabromocyclododecane (HBCDD) and all major diastereoisomers – the reporting threshold is being updated to include “intentionally added”.

The new and modified entries in the DSL are shown in the table at the end of this post. The reference substances and the material class did not change during this update.

Changes to the XML Schema

A new class definition (“Threshold”) was created to pull together the reportableApplication, reportingThreshold, and aboveThreshold attributes.  The re-organization of the attributes offers signfiicant advantage in interpreting material declarations when more than one reporting requirement (i.e. DSL entry) is triggered. This issue is likely to become more common as reporting requirements become more complex and more DSL entries overlap.

The reportable application, reporting threshold and above threshold data fields were previously specified as indepedent attributes within the substance and substance group classes.  They are now grouped together into the “Threshold” class and clearly associated with each other to form a grouping of information that corresponds to a single reporting requirement.

In this way, multiple reporting triggers can be easily recorded for a substance or substance group.  This can occur, for example, when a given substance or substance group that has multiple DSL entry (such as Lead/lead compounds or some of the Phthalate substances) needs to be declared because multiple entries have been triggered. The multiple entries may exist in the DSL because of different applications and/or reporting thresholds. Although multiple DSL entries have been triggered, if there is only one instance of the substance then it would be reported only once in the material declaration file and all of the reporting triggers should be recorded with the substance.

As a consequence of adding the new “Threshold” class, attributes ACB067, ACB068, ACB117, ACB068, ACB069, and ACB118 are no longer required and have been deleted.

Changes to the Developer’s Table

The IEC 62474 Developer’s Table has been updated with three changes

  • added “Threshold” class to replace individual attributes for reportableApplication, reportingThreshold, and aboveThreshold (see description above);
  • modification to the wording and reporting obligation for mass, mass percent, material mass percent reporting obligations;
  • clarification of reporting requirement for mass or masspercent information in product parts.

The working group that originally developed IEC 62474 clarified that the a user creating a material declaration should only provide either mass or mass percent information, but not both. Inconsistency between reported mass and mass percent values can create confusion as to which value is actually correct.  In some cases, differences may be inadvertently introduced due to rounding.  Therefore, the validation team has updated the obligation fields for mass and mass percent to modify the wording  to require either mass or masspercent but not both (to avoid potential inconsistency). The exact wording will vary between mass information for ProductID, MaterialClass, Material, SubstanceGroup and Substance.

The ACB032 and ACB033 entries in the developer’s tables now include comments to clarify that “When ‘ProductID Class’ refers to ‘ProductPart Class’, the Mass (MassPercent) corresponds to one unit of the product part.

The updated XML Schema and developer’s table are version X5.00.  Changes in the developer’s table compared to X4.00 are shown in red font.

Further Information

The declarable substance list (DSL) is available for download at http://std.iec.ch/iec62474. Entries that are new or revised may be identified by a LastRevised date of 2014-09-24 for the DSL and 2014-09-24 for the developer’s table.

For further information on IEC 62474 or for support on your substance management program, please contact ECD Compliance.

New and Modified DSL Entries (MC-2014-01)

Substance GroupSpecific SubstanceCAS numberTypical ApplicationsReportable ApplicationsReporting Treshold
Disodium 4-amino-3-[[4'-[(2,4-diaminophenyl)azo][1,1'-biphenyl]-4-yl]azo] -5-hydroxy-6-(phenylazo)naphthalene-2,7-disulphonate (C.I. Direct Black 38)1937-37-7used in ink for printersAll0.1 mass%
1,2-Benzenedicarboxylic acid, dihexyl ester, branched and linear68515-50-4 Used as a plasticizer for certain plastics and rubbersAll0.1 mass%
Diisononyl phthalate (DINP)28553-12-0, 68515-48-0Used as a plasticizer for PVCAllIntentionally added
Benzo[a]pyrene50-32-8Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersRubber or plastic parts that come into direct, prolonged or repetitive skin or oral cavity contact except those for toys or childcare articles0.0001 mass% of the plastic or rubber part
Benzo[e]pyrene192-97-2Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersRubber or plastic parts that come into direct, prolonged or repetitive skin or oral cavity contact except those for toys or childcare articles0.0001 mass% of the plastic or rubber part
Benzo[a]anthracene56-55-3Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersRubber or plastic parts that come into direct, prolonged or repetitive skin or oral cavity contact except those for toys or childcare articles0.0001 mass% of the plastic or rubber part
Chrysen218-01-9Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersRubber or plastic parts that come into direct, prolonged or repetitive skin or oral cavity contact except those for toys or childcare articles0.0001 mass% of the plastic or rubber part
Benzo[b]fluoranthene205-99-2Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersRubber or plastic parts that come into direct, prolonged or repetitive skin or oral cavity contact except those for toys or childcare articles0.0001 mass% of the plastic or rubber part
Benzo[j]fluoranthene205-82-3Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersRubber or plastic parts that come into direct, prolonged or repetitive skin or oral cavity contact except those for toys or childcare articles0.0001 mass% of the plastic or rubber part
Benzo[k]fluoranthene207-08-9Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersRubber or plastic parts that come into direct, prolonged or repetitive skin or oral cavity contact except those for toys or childcare articles0.0001 mass% of the plastic or rubber part
Dibenzo[a,h]anthracene53-70-3Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersRubber or plastic parts that come into direct, prolonged or repetitive skin or oral cavity contact except those for toys or childcare articles0.0001 mass% of the plastic or rubber part
Benzo[a]pyrene50-32-8Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersRubber or plastic parts of toys and childcare articles that come into direct, prolonged or repetitive skin or oral cavity contact0.00005 mass% of the plastic or rubber part
Benzo[e]pyrene192-97-2Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersRubber or plastic parts of toys and childcare articles that come into direct, prolonged or repetitive skin or oral cavity contact0.00005 mass% of the plastic or rubber part
Benzo[a]anthracene56-55-3Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersRubber or plastic parts of toys and childcare articles that come into direct, prolonged or repetitive skin or oral cavity contact0.00005 mass% of the plastic or rubber part
Chrysen218-01-9Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersRubber or plastic parts of toys and childcare articles that come into direct, prolonged or repetitive skin or oral cavity contact0.00005 mass% of the plastic or rubber part
Benzo[b]fluoranthene205-99-2Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersRubber or plastic parts of toys and childcare articles that come into direct, prolonged or repetitive skin or oral cavity contact0.00005 mass% of the plastic or rubber part
Benzo[j]fluoranthene205-82-3Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersRubber or plastic parts of toys and childcare articles that come into direct, prolonged or repetitive skin or oral cavity contact0.00005 mass% of the plastic or rubber part
Benzo[k]fluoranthene207-08-9Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersRubber or plastic parts of toys and childcare articles that come into direct, prolonged or repetitive skin or oral cavity contact0.00005 mass% of the plastic or rubber part
Dibenzo[a,h]anthracene53-70-3Impurities in carbon black, which is used as coloring agent in plastics and softener in rubbersRubber or plastic parts of toys and childcare articles that come into direct, prolonged or repetitive skin or oral cavity contact0.00005 mass% of the plastic or rubber part
Brominated flame retardants (other than PBBs, PBDEs, or HBCDD)See Reference Substance worksheet for more detailsSee Reference Substance worksheet for more detailsFlame retardant for housing, connectors, package molding sealingPlastic materials except printed wiring board laminates0.1 mass% of bromine in plastic materials
Chlorinated Flame Retardants (CFR)See Reference Substance worksheet for more detailsSee Reference Substance worksheet for more detailsflame retardant for housing, connectors, package molding sealingPlastic materials except printed wiring board laminates0.1 mass% chlorine in plastic materials
Shortchain Chlorinated Paraffins (C10 – C13)See Reference Substance worksheet for more detailsSee Reference Substance worksheet for more detailsPlasticizer for PVC, flame retardantAllIntentionally added or 0.1 mass%
Perfluorooctane sulfonates (PFOS)See Reference Substance worksheet for more detailsSee Reference Substance worksheet for more detailsAntistatic agent for films and plasticsTextiles or other coated materials.
Intentionally added or 1 microgram/m2 of coated material
Perfluorooctane sulfonates (PFOS)See Reference Substance worksheet for more detailsSee Reference Substance worksheet for more detailsAntistatic agent for films and plasticsAll except textiles or other coated materials.
Intentionally added or 0.1 mass% of the part (as the sum of PFOS)
Hexabromocyclododecane (HBCDD) and all major diastereoisomersSee Reference Substance worksheet for more detailsSee Reference Substance worksheet for more detailsFlame retardant; mainly used for expanded polystyrene and some types of fiberAllIntentionally added or 0.1 mass%

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